News & Analysis as of August 3, 2025

Money Services Business

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

Exam Time: Understanding Exam Ratings

Ankura on 5/23/2025

It is inevitable that your Money Service Business (MSB) will eventually receive a much-anticipated (or in some instances, much-dreaded) Exam Engagement letter from one or more states. MSBs licensed in 40 or more states meet...more

Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act

King & Spalding on 4/21/2025

The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

Pillsbury Winthrop Shaw Pittman LLP on 3/20/2025

On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more

Superman29 - Welcome to the Phantom Zone

Polsinelli on 8/10/2020

In a lesson to everyone that the use of foolish monikers will come back to haunt you, Kais Mohammad, 36, a.k.a. “Superman29,” has met his Kryptonite - the U.S. Department of Justice. ...more

FinCEN Advisory Highlights Money Laundering Risks Related to Fentanyl Trafficking

Ballard Spahr LLP on 8/30/2019

On August 21, 2019, FinCEN issued an advisory (the “Advisory”) alerting financial institutions to various financial schemes and mechanisms employed by fentanyl and synthetic opioid traffickers to facilitate the illegal...more

If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)

Foodman CPAs & Advisors on 7/22/2019

FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more

The Banking Stepchild: Money Service Businesses

The Volkov Law Group on 3/22/2016

Sometimes risk analysis can result in paralysis. Finding your risk tolerance and applying it to specific situations requires a nuanced approach. I am always wary of anyone who tells me categorical rules – e.g. we do not...more

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